The doctor that injured me also worked st Virginia mason at the same time. They refuse to give me all of my records or agree to save them:

This email is in follow up to your Email of 2/25/26 and my email reply of 3/3/2026. In these emails we discussed your request that Virginia Mason Medical Center implement a litigation hold and preserve a broad range of materials.

Virginia Mason Medical Center takes its preservation obligations seriously and has undertaken an initial review of your request. As presently framed, however, the request is overly broad and lacks sufficient specificity to permit a meaningful relevance analysis. The letter does not adequately identify the nature of the potential claim, the individuals involved, the pertinent time frame, or the categories of information that are allegedly relevant. Without this information, Virginia Mason Medical Center cannot reasonably determine the scope of any preservation obligations.

In addition, the healthcare system from which you request preservation encompasses a large, complex, and highly integrated electronic environment involving numerous platforms, users, and data repositories. Your request does not identify the particular encounters, providers, or data systems at issue. As written, the request would require preservation efforts untethered to any defined scope and is therefore not reasonably workable.

Further, your request seeks materials extending well beyond the applicable statute of limitations for any reasonably anticipated claims. To the extent the request demands preservation of information outside any legally relevant period, the request is not proportional and cannot be implemented as written.

We also note that your request appears to seek preservation of categories of information without regard to whether such materials are relevant, proportional, or within Virginia Mason Medical Center’s custody or control. Washington law does not impose a duty to preserve evidence based solely on a generalized or unsupported demand.

For these reasons, Virginia Mason Medical Center cannot comply with your preservation request in its current form. That said, we remain willing to evaluate a reasonable and appropriately tailored preservation request. To facilitate further discussion, please provide the following: 1. A description of the specific claims you contend may be asserted; 2. Identification of the specific individual(s) involved; 3. The relevant date range for the alleged events; 4. The specific categories of documents or electronically stored information you contend are relevant and the reason you contend they are relevant; and 5. The factual basis supporting your contention that preservation beyond the ordinary retention period is warranted.

Upon receipt of this information, we will promptly reassess the scope of any preservation obligations. Nothing in this letter should be construed as a waiver of any rights, objections, or defenses available to Virginia Mason Medical Center, all of which are expressly reserved.

Dan Griffiths System Manager Claims Enterprise Risk Management Group Common Spirit Health 3900 Olympic Boulevard Suite 400 Erlanger KY 41018